r
DOCKET SECTION
RECEIVEI)
BEFORE THE
SEP29
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
POSTAL
RblCCC;4HISSIC
OFFICEOi T/it SECii?:ir\d?
Docket
j
No. R97-1
RESPONSE OF UNITED STATES POSTAL SERVICE
WI’TNESS PLUNKETT TO INTERROGATORIES
OF
DAVID B. POPKIN
REDIRECTED FROM #HE POSTAL SERVICE
(DBPIUSPS-24.
25(A, C-G, K-U), 26(C-D); 27, 28(C-V). 29, 3O(C-J), 31-32,
33(A-E. M-S), 34, 36, 38(C-D), 50(C-E), 51.
53(.A-E, H, J-N, P-S, U-W, BB-FF), 62(H-K), AND 64)
The United States Postal Service hereby provides responses of witness Plunkett
to the following
interrogatories
of David B. Popkin:
DBP/USPS-T24,,
25(a, c-g, k-u),
26(c-d), 27, 28(c-v). 29, 3O(c-j), 31-32, 33(a-e, m-s), 34, 36, 38(c-d), 50(c-e),
53(a-e. h, j-n, p-s, u-w, bb-ff). 62(h-k), and 64, tiled on September
redirected from the Postal Service.
DBPIUSPS-28(a-b),
51.
10, 1997, and
Objections were filed on September
25, 1997 to
33(f-I), 50(a-b), and 53(t, x, and y).
Each interrogatory
is stated verbatim and is followed by the response.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
,
David H. Rubin
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-l 137
(202) 268-2986; Fax -5402
September 29, 1997
'-i 56 pti ‘97
RESPONSE OF POSTAL SERVICE WITNESS PLUNKEl-r
INTERROGATORIES
OF DAVID B. POPKIN
TO
[a] Confirm, or explain if you are unable to do so, that Return
DBPIUSPS-24
Receipt for Merchandise service will provide the following four services to a mailer: I.
Proof that the article was mailed [namely, the mailing receipt may be postmarked at the
office of mailing], 2. The ability to utilize Restricted Delivery will be permitted, 3. The
article will be signed for by the addressee and the record of delivery will be maintained
by the office of delivery, and 4. The ability to receive proof of delivery will be available
[namely, the Return Receipt PS Form 38111. [b] Enumerate any other services that
are available to the user of this service or indicate that there are none. This only
includes those services that one would obtain by utilizing the specific Return Receipt for
Merchandise and not other services that may be utilized for the parcel such as
insurance, COD, etc. [c] Confirm, or explain if you are unable to clo so, that an article
which is sent by Certified Mail - Return Receipt Requested will provide to the mailer the
same identical services available as noted for Return Receipt for Merchandise in
subparts a and b above. This assumes that I am able to utilize the service either by the
contents of the parcel, the level of service that I desire, or the rate at which I send the
article. [d] Confirm, or explain if you are unable to do so, that if I lhave a l-1/2 pound
domestic parcel containing merchandise which I desire to send by Priority Mail, the
postage will be $3.00. [e] Confirm, or explain if you are unable to do so, that if I wish to
utilize the Return Receipt for Merchandise service in connection with this parcel, I will
pay an additional $‘I .20 or a total of $4.20 for the service. [f] Confirm, or explain if you
are unable to do so, that if I wish to utilize the Certified Mail - Return Receipt Requested
service in connection with this parcel, I will pay an additional $2.45 [$1.35 Certified Mail
fee and $1 .lO Return Receipt fee] or a total of $5.45 for the service. [g] List and
explain any reasons why a knowledgeable mailer should utilize the more expensjve
Certified Mail - Return Receipt Requested service over the less expensive Return
Receipt for Merchandise service when the service received will be identical.
[h]
Confirm that Priority Mail is a subclass of First-Class Mail and is sealed against Postal
Inspection. [i] Confirm, or explain if you are unable to do so, that the Postal Service will
not be able to determine whether a Priority Mail parcel contains merchandise and
therefore may utilize the Return Receipt for Merchandise service or contains nonmerchandise and therefore may not utilize the service. h] What penalty, if any, is there
for a mailer who is already utilizing Priority Mail service [either because of the weight
and/or desire for the delivery standards] and who wants some form of mailing receipt /
proof of delivery service utilizing the Return Receipt of Merchandise service [as
opposed to Certified Mail - Return Receipt Requested] regardless of whether or not the
parcel contains merchandise?
[k] Confirm, or explain if you are unable to do so, that
the proposed rate for Return Receipt for Merchandise is $1.70 ancl the total fee for
Certified Mail - Return Receipt Requested is $1.55 plus $1.45 or $3.00. [I] Explain why
in both the present and proposed rate schedules, the fee for Certified Mail - Return
Receipt Requested is between 176% and 204% of the fee for Return Receipt for
Merchandise when both services provide identical benefits to the mailer.
DBP/USPS-24
Response:
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
a. Not confirmed.
Restricted delivery service is not available to customers who
purchase return receipt for merchandise
service.
b. There are no other services available.
c. Not confirmed.
See response to subparts (a) and (g).
d. Confirmed.
e. Confirmed.
f.
Confirmed.
9, Customers purchasing certified mail and return receipt service are also able to
purchase restricted delivery, and are able to request return receipts after mailing;
services which are unavailable to customers purchasing
merchandise
service.
Furthermore,
return receipt for
customers using certified mail and return receipt
may deposit their mail in street letterboxes,
post office maildrops. or any other
receptacle for First-Class Mail subject to DMM § 912.2.5.
merchandise
Return receipt for
customers must mail articles at a post office, branch, or station or give
them to a rural carrier (DMM 5 917.2.1).
h. Confirmed.
i.
Not confirmed.
As indicated in my response to subpart (g), customers must present
these articles to USPS employees for acceptance.
The physical ciharacteristics of
the mailpiece (if it is flat for example) may indicate that the article does not contain
merchandise.
i.
I am unaware of any attempt to impose penalties on mailers who attempt to
circumvent DMM provisions as described.
Typically, when an employee becomes
aware that.a customer is using a service for which they are not eligible, the practice
is to inform the customer of the appropriate
regulation.
However, as is pointed out
in subpart (h), Priority Mail is sealed against inspection, making detection of such
pieces difficult. To some extent, the Postal Service relies on the integrity of its
customers not to send non-merchandise
merchandise.
using a product called return receipt for
RESPONSE OF POSTAL SERVICE WITNESS PLUNKE-iY TO
INTERROGATORIES
OF DAVID B. POPKIN
k. Confirmed.
I,
Costs for return receipt for merchandise
certified mail and return receipts.
are less than the combined costs for
See LR-H-107, and USPS-T-39, WP-17, page 1.
Moreover, the services are not identical.
See response to subpalrl (g).
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT
INTERROGATORIES
OF DAVID B. POPKIN
TO
DBPIUSPS-25
[a] Confirm, or explain if you are unable to do s,o, that the
proposed fee for Certified Mail will be $1.55, for Return Receipt for Merchandise will be
$1.75, and for individual Certificate of Mailing will be $0.60. [b] Confirm, or explain if
you are unable to do so, that the cost coverage Certified Mail will be 133%. [c] What
will the cost coverage be for Return Receipt for Merchandise? [d] VVhat will the cost
coverage be for an individual Certificate of Mailing? [e] Based on the fees shown in
subpart a and the cost coverage values shown in subparts b through1 d, what will the
costs be for each of the three services listed in subpart a. [f] Is the cost value
determined by dividing the proposed rate by the decimal value of the cost coverage
percent [for example, a fee of $2.00 with a cost coverage of 164% wsould have a cost of
$2.00 divided by 1.64 or $1.221 [g] If not, explain how it is calculated. [h] Is there any
interaction between the rates and costs for Certified Mail vs. those for Return Receipt
service or have the two rates been evaluated independently of each (other? [i] Fully
explain any interaction. u] What percentage of Certified Mail articles utilize Return
Receipt Service? [k] With respect to these three services, confirm, or explain if you are
unable to do so, that there is no added service or costs associated with the processing
or handling of the article from the time of the completion of its acceptance into the mail
stream at the acceptance postal facility to the time at which it becomes necessary to
“trap” the article at the delivery office so that it may be properly handled for the type of
service being requested. [I] Confirm, or explain if you are unable to do so, that there
are no costs associated at the delivery office with respect to articles for which a
Certificate of Mailing had been issued and therefore there will be no costs associated
with this service once the completion of its acceptance into the mail stream at the
acceptance postal facility has been completed. [m] For each of the three services, list
each of the specific cost elements which relate to and are charged to that service and
the costs associated with that element for the time up until dispatch of the article from
the acceptance postal facility. These cost elements should include the following [if the
costs for any of these elements are not charged to the service, so indicate. If any
additional items apply, so indicate them and provide the data]: 1. Cost of advertising
the service, 2. Cost of training employees regarding the service, 3. Cost for designing
and printing the necessary forms, 4. Cost for shipping, storing, and distributing the
forms, 5. Cost for window services to explain the service, and 6. Cosl: for the
acceptance of the article by the acceptance office, including, but not limited to,
observing the article, postmarking the receipt, discussion with the customer, and
possible record keeping. [n] For Certified Mail and Return Receipt for Merchandise
services, list each of the specific cost elements which relate to and are charged to that
service and the costs associated with that element for the time starting at the point at
which the article is “trapped” at the delivery office. These cost elemems should include
the following [if the costs for any of these elements are not charged to the service, so
indicate. If any additional items apply, so indicate them and provide the data]: 1. Cost
of “trapping the article” at the delivery office, 2. Cost of any special handling that may
be required to process these at the delivery office, 3. Cost of turning accountability for
the articles over from lthe processing employee[s] to the delivery employee, 4. Cost
associated with the delivery of the article by the delivery employee to thie addressee, 5.
Cost for “clearing” the delivery employee of the accountability after the return to the
office, 6. Cost for subsequent delivery attempts for articles returned after the first
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
attempt, 7. Cost for returning undeliverable articles, 8. Cost for filing delivery receipts,
9. Cost for handling inquiries received for the article, 10. Cost for processing the PS
Form 3811 for Return Receipt for Merchandise service at the delivery office before it is
entered into the mail stream, and 11. Cost for transmission of the F’S Form 381 1 from
the delivery office back to the original sender of the parcel. [o] If subparts k and I result
in any added costelements, provide the data requested in subparts m and n for them.
[p] With respect to the three separate costs that you provide for each of the three
services in your response to subpart m, if the value is different between the three
services for the same cost element, fully explain the difference for each separate cost
element. [q] Same as subpart p except for the two services and your responses to
subpart n. [r] Same as subpart p for any responses to subpart o. [si] If all of the costs
enumerated in subparts m through o do not add up to the corresponding total cost
provided in subpart e, explain the reasons for the difference. [t] Do the costs specified
in subpart n item 11 match the cost of processing and delivery of a post card or
stamped card? [u] If not, explain why not.
DBPIUSPS-25
Response:
a. Confirmed for certificates of mailing. Not confirmed for return receipt for
merchandise,
which has a proposed fee of $1.70.
b. Answered by witness Needham.
c. Cost coverages are normally calculated for subclasses or special services, not for
individual components
of a particular special service.
coverage for return receipts for merchandise
However, the implied cost
is 147 percent.
d. Cost coverages are normally calculated for subclasses or special s’ervices, not for
individual components
of a particular special service.
However, the implied cost
coverage for an individual certificate of mailing is 122 percent.
e. See LR-H-107.
Unit costs for return receipt for merchandise
certificates of mailing are $1.16 and $0.49 respectively.
and individual
Note that these costs are
not based on fees and implicit cost coverages.
f.
No. Cost coverages are derived by dividing the total revenues of a service by the
volume variable costs of that service.
components
Implied cost coverages for specific
of a service can be calculated by dividing the fee by the unit cost of a
particular component,
g. See response to subpart (f)
h. Answered by witness Needham.
RESPONSE OF POSTAL SERVICE WITNESS PLUNKEl-T
INTERROGATORIES
OF DAVID B.POPKlN
i.
Answered by witness Needham.
j.
Answered by witness Needham.
k. Confirmed for return receipt for merchandise
I.
TO
and certificates of mailing.
Confirmed.
m-s. For the Postal Service’s cost analysis of return receipt for merchandise,
response to DFC/USPS-T40-9,
see
and for Certificates of Mailing see LR-H-107 page 18.
t-u. The cost study supporting return receipts uses the processing and delivery cost of
single piece cards as a proxy for the actual cost of returning a return receipt.
H-107, p. 39.
See LR-
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
DBP/USPSQ6
[c] Confirm, or explain if you are unable to do so, that when
delivering a Return Receipt for Merchandise article, that the delivery employee must
obtain two separate signatures from the addressee, one on the Postal Service delivery
record [irrespective of whether there is a single article to deliver this way or multipk
articles for delivery on some form of manifest] and the second on the Return Receipt
card PS Form 3811. [d] Confirm, or explain if you are unable to do so, that the time
and therefore costs for obtaining both signatures for Return Receipt for Merchandise
service are charged to that service since there is a single fee.
DBP/USPS-26
Response:
c. Confirmed
d. Please see my response to DFCAJSPS-T40-20.
..--
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
DBP/USPS-27
[a] Confirm, or explain if you are unable to do so, that effective
June 8, 1997, the service for return receipts changed requiring the delivery employee to
indicate the address of delivery if different from the address on the mailpiece. [b]
Confirm, or explain if you are unable to do so, that the service available on June 8th
represents a difference in the service that was provided at the basic fee on June 7th.
[c] Other than the mention on Page 9 of the May 22, 1997 Postal Bulletin, provide
references and copies of all directives issued by Headquarters notifying the field of this
change. [d] Has the Postal Service conducted any tests to determine the level to which
the field is complying with the requirements to provide an updated address when
appropriate? [e] If so, provide details and results of the tests. [f] If not, explain why
not including reasons why one would consider Return Receipt service to be a quality
service, particularly with respect to providing customers with updateo addresses.
DBPIUSPS-27
Response:
a. Confirmed.
b. Confirmed.
c. Materials will filed as LR-H-286.
d. I am not aware of any tests that have been conducted thus far.
e. NA
f.
As barely three months have passed since implementation
be premature.
Moreover, any of the headquarters
a test at this time would
offices that would typically
perform such tests have been devoting the bulk of their resources to the preparation
and litigation of R97-1.
RESPONSE OF POSTAL SERVICE WITNESS PLUNI<ElT
INTERROGATORIES
OF DAVID B. POPKIN
TO
DBP/USPS-28
[a] Confirm, or explain if you are unable to do so, that Section
822.111 of the Postal Operations Manual [POM] requires that the delivering carrier or
window clerk will obtain the signature or authorized signature stamp of the recipient of
an article utilizing the Return Receipt Service. [b] Confirm, or expl.ain if you are unable
to do so, that POM Section 822.11 1 also requires the delivery employee must complete
the date of delivery if the addressee has not already done so. [c] Would it be
reasonable to expect the delivery employee to check to ensure that: the Return Receipt
has been properly signed? [d] Would it be reasonable to expect the delivery employee
to check to ensure that the Return Receipt has the name of the addressee printed in
addition to the signature? [e] Would it be reasonable to expect the delivery employee
to check to ensure that the Return Receipt has the correct date of delivery entered on
it? [f] Would it be reasonable to expect the delivery employee to check to ensure that
the Return Receipt has been properly completed?
[g] Would it be reasonable to
expect the delivery employee to make any necessary corrections to the information
provided on the return receipt? [h] Explain any negative answers to subparts c through
g. [h] Will the delivery employee referenced in POM Section 822.111 always be an
employee of the United States Postal Service? [i] If your response to subpart h is not
an unqualified yes, list all examples and instances in which the delivery employee will
not be a USPS employee. h] Do the requirements of POM Section 822.111 apply to
the necessity of having the delivery employee ensure that the Return Receipt is
completed at the time of delivery [the time at which the custoldy of the mail is
transferred from the control of the United States Postal Service to the control of the
addressee]?
[k] If not, explain any instances in which it is not required. [I] Do the
requirements of POM Section 822.111 apply to the necessity of having the delivery
employee ensure that the Return Receipt is completed at the tim’e of delivery with
respect to all agencies, departments, or organizations of the federal government?
[m]
Same as subpart I except with respect to those of any state or local government.
[n]
Same as subpart I except with respect to delivery to any non-government addressee.
[o] Do the requirements of POM Section 822.111 apply to the necessity of having the
delivery employee ensure that the Return Receipt is completed at the time of delivery
regardless of the number of return receipts that are involved in the delivery?
[p]
Explain and list any instances with respect to any negative answers to subparts I
through o. [q] Confirm, or explain if you are unable to do so, that the delivering
employee will be required in all instances to determine if the delivery address differs
from the original address shown on the article and if so to provide the new address on
the Return Receipt card. [r] Confirm, or explain if you are unable to do so, that the
delivering employee will be required in all instances to determine if the delivery address
differs from the original address shown on the article and if not to check the box on the
return receipt card to indicate that the article was delivered to the same address as
originally addressed.
[s] Confirm, or explain if you are unable to do so, that the
requirements specified in subparts q and r will apply to all types of addressees
including, but not limited to, those types mentioned in subparts I through o. [t] Confirm,
or explain if you are unable to do so, that the delivering employee will be required in all
instances to give all return receipts to the clearing clerk daily. [u] Confirm, or explain if
you are unable to do so, that subpart t means that for all return receipts which are being
requested for mail which is delivered on a given day will be turned over to the clearing
9
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT
INTERROGATORIES
OF DAVID 6. POPKIN
TO
clerk that same day. [v] Confirm, or explain if you are unable to do so, that the
requirements specified in subpart t will apply to all types of addresisees including, but
not limited to, those types mentioned in subparts I through o.
DBP/USPS-28
Response:
a-b Objection filed September 25, 1997.
c-h. POM 5 822.111 states that the delivering employee must examine the card for
completeness
and make any necessary corrections.
What is reasonable depends on
the circumstances.
h. No.
i.
The delivering employee may be a highway contract route driver.
j-p. POM 9 822.111 does not appear to require completion at the time of delivery.
q. Confirmed.
r. Confirmed.
s. Confirmed.
t.
Confirmed.
u. Confirmed, when practicable.
POM 5 822.112 gives the clearing employee until the
next workday to mail the completed return receipt to the customer.
v. Confirmed.
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIESOF
DAVID 6. POPKIN
DBP/USPS-29
[a] Confirm, or explain if you are unable to do so, that Section
822.112 of the Postal Operations Manual requires that the clearing clerk must evaluate
all return receipts that have been turned in to ensure that they are properly completed.
[b] Would it be reasonable to expect the clearing clerk to check to ensure that the
Return Receipt has been properly signed? [c] Would it be reasonable to expect the
clearing clerk to check to ensure that the Return Receipt has the name of the
addressee printed in addition to the signature? [d] Would it be reasonable to expect
the clearing clerk to check to ensure that the Return Receipt has the correct date of
delivery entered on it? [e] If there are any instances where the return receipt is not
given to the clearing clerk on the date of delivery, explain how the (clearing clerk would
be aware of the date of delivery? [f] Would it be reasonable to expect the clearing
clerk to check to ensure that any requirements for restricted clelivery have been
complied with? [g] Would it be reasonable to expect the clearing clerk to check to
ensure that any requirements for notifying the sender of a new address have been
complied with? [h] Would it be reasonable to expect the clearing clerk to check to
ensure that any requirements for notifying the sender that there IS no new address
[namely, the box has been checked to show this] have been complied with? [i] What
corrective action should the clearing clerk take if in evaluating a return receipt it is
noticed that 1. the card is not properly signed, 2. the name of the ,person signing has
not been properly printed, 3. the correct date of delivery has not been shown, 4. the
restricted delivery requirements have not been complied with, 5. a new address has
not been provided when there is one, or 6. the box has not been checked when there
is no new address. [j] Confirm, or explain if you are unable to do so, that all return
receipts must be mailed [namely, placed into the mail stream for processing and
transporting and delivery to the sender] no later than the first workday after delivery. [k]
Explain why POM Section 822.112 does not require that the clearing clerk mail the
return receipt card on the date of delivery rather than allowing it to be held until the next
workday. [I] Confirm, or explain if you are unable to do so, that the requirements
specified in subparts b through j will apply in all instances regardless of the type of
addressee or the number of return receipts involved. [m] Confirm, or explain if you are
una,ble to do so, that the clearing clerk referenced in POM Seclrion 822.11 is an
employee of the United States Postal Service.
DBPAJSPS-29
Response:
a. Not confirmed.
POM 5 822.112 states: “The clearing clerk must check all return
receipts to make sure that they are properly signed and dated.”
b. In general, yes.
c. This checking would go beyond what’s required by POM 9 822.112
d. In general, yes.
RESPONSE OF POSTAL SERVICE WITNESS PLUNKET-T TO
INTERROGATORIES
OF DAVID B. POPKIN
e. The clearing employee could be informed by the delivering employee in such cases.
f.
In general, yes.
g. In general, this checking would go beyond what’s required by POM 5 822.112.
h. In general, this checking would go beyond what’s required by POM § 822.112.
i.
For subparts 1,2,3, and 5, clearing clerk should notify delivering employee. For
subpart 4, as indicated in POM 5 822.112, a corrected return receipt should be
obtained from the addressee.
j.
Confirmed, based on POM 3 822.112.
k. In some cases, carriers may be cleared of their accountable
items after the final
dispatch of outgoing mail has left the delivery unit. In addition, the return receipt
might require corrective action.
I.
Not confirmed.
Please see my responses to parts b through j. The POM does not
provide any special procedures for different types of addresses or different numbers
of return receipts,,
m. Confirmed, to the best of my knowledge.
12
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
lNTERROGATORlESOFDAVlDB.POPKlN
DBPIUSPS-30
With respect to the utilization of other than a signature by hand on
the return receipt card, confirm or explain if you are unable to do so, that POM Section
822.2 requires that, [a] In those cases where the article is addressed to a federal or
state official or agency, a rubber stamp showing the name of the agency or organization
may be utilized.
[b] This rubber stamp must show the name of the agency or
organization and not just the name of an individual. [c] The ability to utilize a printed
rubber stamp or other automated means [as opposed to one which has a facsimile of a
written signature of an individual] may only be used by a federal or state agency. [d] A
federal agency is one in which the employees of the agency are employees of the
United States Government.
[e] A state agency is one in which the employees of the
agency are employees of one of the 50 states of the United States of America. [f] This
provision does not apply to other governmental agencies such as, mlulti-state agencies,
counties, municipalities, school districts.
[g]
This provision cloes not apply to
companies or other non-governmental
agencies.
[h] For all addressees other than
federal and state agencies, the rubber stamp or other automated means must include a
facsimile, hand-written
signature of the individual who is authorized to accept
accountable mail. [i] The type of addressee noted in subpart h may not utilize ‘a rubber
stamp or other automated means which contains printed information only [such as the
name of the agency]. h] Explain any non-confirmations.
DBP/USPS-30
Response:
a. Objection filed.
b. Objection filed,
c. Confirmed.
d. I can not confirm that this precise interpretation
is implied by the POM.
e. I can not confirm that this precise interpretation
is implied by the POM.
f.
The POM specifies only state and federal government
g. Not confirmed.
agencies
POM 9 822.22 applies to other large well-known organizations
approval from the local postmaster.
h. That appears to be what POM 5 822.22 says.
i.
That appears to be what POM § 822.22 says
j.
See parts d-i.
with
RESPONSE OF POSTAL SERVICE WITNESS PLUNKEl-T
INTERROGATORIES
OF DAVID 13.POPKIN
TO
DBPIUSPS-31
[a] Confirm that on August 1, 1996, Sandra D. Curran, Acting
Manager, Delivery, sent a letter to all District Managers - Subject: Failure to Obtain
Signature on PS Form 3811 Domestic Return Receipt. [b] Confirm, or explain if you
are unable to do so, that this letter indicates that all District Managers are to take a
proactive approach with all of their delivery offices to ensure that return receipts are not
being signed for at a “later”, more convenient time and therefore this would require that
the return receipt be signed for at the time of delivery. [c] Confirm, or explain if you are
unable to do so, that this letter indicates that any long standing, unofficial arrangements
that promote or provide for exceptions to the state procedures for “convenience” should
be voided if they exist. [d] Confirm, or explain if you are unable to do so, that this letter
indicates that a lack of realization by some employees that the customer has paid for
this service and any arrangement that makes it easier for the addressee at the expense
of that service should not be tolerated. [e] Is this letter still in force? [f] If not, provide
a copy of the letter which superseded or modified it. [g] Provide copies and references
of any directives that have been issued since August 2, 1996 which relate to the
provision of return receipt service.
a. Confirmed
b. Not confirmed.
The letter asks managers to review current practices and void where
necessary, those that are inconsistent with official procedures.
c-d. Confirmed.
e. I am not aware of any subsequent
superseded
it
f. Not applicable
g. Not applicable.
letters which would have ciountermanded
or
RESPONSE OF POSTAL SERVICE WITNESS PLUNKET-T TO
INTERROGATORIES
OF DAVID B. POPKIN
DBP/USPS-32
[a] Bottom line, is it a requirement of the United States Postal
Service that all accountable mail, including any return receipts that are associated with
the mail piece, be signed [this includes the use of a signature stamp under the
provisions of POM Section 822.21 for by the addressee at the time of delivery [namely,
when the control of the mail piece transfers from the United States Postal Service to
that of the addressee] and that the requirements for the completion of the return receipt
also be completed at the time of delivery in accordance with the provisions of POM
Section 822 and that this applies to any and all addressees throughout the United
States who might receive accountable mail and also applies regardless of the quantity
of mail involved. [b] If your response to subpart a is not an unqualified yes, provide a
complete listing of all exceptions to the requirement and the authclrity authorizing that
exception, [c] Confirm, or explain if you are unable to do so, that i:he cost for a return
receipt is presently $1 .lO and that this charge will apply for each separate accountable
mail piece for which return receipt service is desired. [d] Confirm, or explain if you are
unable to do so, that should there be 10,000 accountable mail pieces requesting return
receipt service being delivered to a single addressee on a given d#ay that each of the
senders paid a fee of $1 .lO for the return receipt and that the total revenue received by
the Postal Service for processing all ten thousand return receipts will be $11,000. [e]
Confirm, or explain if you are unable to do so, that, on average when there is more than
one return receipt involved for a given addressee, the average cost for processing each
single return receipt will be less than the cost that would be entailed if the addressee
only received a single mail piece requesting return receipt service. In other words, if the
cost for handling a single return receipt on average was fifty cents, then the total cost
for handling 100 return receipts for a single addressee at one time would be less than
fifty dollars [resulting in an average cost of less than fifty cents each]. [f] Do the cost
figure for return receipt service take into account the potential savings in delivering
multiple pieces at the same time?
a. This is the goal.
b. As there is no requirement,
there can be no exceptions.
In some cases it is possible
that the signature takes place after delivery.
c. Confirmed,
merchandise
assuming
a regular
return
receipt
rather than a return
receipt
for
or return receipt after mailing.
d. Your multiplication
appears to be correct, and the fee for each return receipt would
be $1.10.
e. Having no available study to support this conclusion,
I can not confirm. However,
your assumption appears reasonable insofar as it suggests that some costs can be
avoided when a carrier delivers multiple pieces with return receipts.
I would note
‘4
RESPONSE OF POSTAL SERVICE WITNESS PLUNKIETT TO
INTERROGATORIES
OF DAVID B.POPKlN
however, that the nature of return receipt service suggests that multiple pieces
requesting return receipts addressed to a single recipient are relatively rare.
f.
I would expect that the cost figure does reflect these savings.
It is my understanding
that the original return receipt cost study, which is updated in LR-H-107, collected
data on the time and volume for return receipts at 26 CAG A,B, arid C post offices.
These data most likely include some return receipts for multiple pieces delivered at
one time.
RESPONSE OF POSTAL SERVICE WITNESS PLUNKET-T TO
INTERROGATORIES
OF DAVID B. POPKIN
DBPIUSPS-33
In order to determine that the Return Receipt service provides a
value to the mailer, [a] Enumerate and provide details of all studies, and tests that have
been performed or conducted by the Postal Service in the past seven years [since
Docket R90-l] to determine the mailing public’s needs and desires ;for return receipt
service. [b] Same as subpart a except to determine the quality of service being
received by return receipt users. [c] Same as subpart a except to cletermine the extent
to which the return receipt service is being provided as mandated in the regulations. [d]
Explain why the responses to subparts a through c indicate that the Postal Service is
making a concerted effort to provide a quality service. [e] Confirm, or explain if you are
unable to do so, that one of the purposes of the return receipt is to provide evidence of
delivery to the sender and that this evidence is being provided by an independent third
party, namely the Postal Service. [f] Confirm, or explain if you are unable to do so, that
the Postal Service used to apply the red validating stamp to return receipts and that this
procedure was terminated. [g] When and why was the use of this procedure
terminated and provide copies of the directive doing so? [h] Wouldn’t the date on the
red validating stamp be more likely to be correct than a date that was handwritten? [i]
Wouldn’t the presence of the red validating stamp on the return receipt provide a
greater level of authenticity of the return receipt than one without it? [i] Explain any
negative responses to subparts h and i particularly in light of the desire to provide a
quality product. [k] Confirm, or explain if you are unable to do so, that the application
of a red validation stamp impression on a return receipt by other than an authorized
Postal Service employee would be a violation of the law. [I] Are there any plans to
resume the use of the red validating stamp? [m] When will the new form be available
for return receipts which includes the box for indicating that the article was delivered as
addressed? [n] Will the instructions for the implementation of these new forms call for
the immediate removal from service of the existing forms to ensure maximum use of the
new form? [o] Confirm, or explain if you are unable to do so, that there are ti’mes when
the actual date of delivery is significant to the mailer utilizing return receipt service. [p]
Confirm, or explain if you are unable to do so, that there are times whlen name of the
recipient is significant to the mailer utilizing return receipt service. [q] Confirm, or
explain if you are unable to do so, that there are times when prompt notification of
delivery is significant to the mailer utilizing return receipt service. [r] Confirm, or explain
if you are unable to do so, that provision of the return receipt as proof of delivery and
proof of delivery date having been furnished by an independent, disinterested third
party, such as the Postal Service, is significant to the mailer at times. [s] Confirm or
explain if you are unable to do so, that failure of the Postal Service to process return
receipts in the manner specified in the regulations may increase the likelihood of a
decrease in value to the mailer who is expecting one of the services noted in subparts o
through r.
a. Witness
Needham
discussed
one study
customers desire return receipt service.
66-67; LR-SSR-110.
showing
that
most
certified
mail
See Docket No. MC96-3, USPS-T-6 at
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT
INTERROGATORIES
OF DAVID 6. POPKIN
TO
b. I am not aware of any such studies.
c. I am not aware of any such studies.
d. The Postal Service utilizes many methods to ensure that employees and
managers provide the services customers expect.
The fact that studies have not
been performed at a national level to determine the level to which the Postal
Service has been able to meet this goal vis a vis return receipts should not be
construed as meaning that there has been no concerted effort toward this end.
Local managers have access to customer feedback via consumer service cards
and other means.
performance
They are expected to utilize these data to improve their
not only as regards return receipts, but for all products and
services.
e. Confirmed.
f-l. Objection filed September 251997.
m. This has not yet been determined.
n. Typically, destruction of existing forms is called for only when a change in the
nature of the service requires.
For instance, when a block for the name of the
addressee was added to return receipts, offices were instructed to destroy the
old return receipts upon receipt of the new version.
In this case, the nature of
the service is not changing; the new receipt will provide an enhanced method for
providing the same service.
Consequently
it is unlikely that the old forms will be
destroyed, though that decision has not yet been made.
o. Confirmed.
p. Confirmed.
q. Confirmed.
r.
Confirmed.
s.
Confirmed.
RESPONSE OF POSTAL SERVICE WITNESS PLUNKET-T TO
INTERROGATORIES
OF DAVID 8. POPKIN
DBP/USPS-34
DMM Section S915.1.6 states, Return receipt fees are refunded
only if the USPS fails to furnish a return receipt. May a refund be claimed for the
following: [a] The return receipt which is received back is not signed. [b] The return
receipt which is received back does not have the printed name of the recipient. [c] The
return receipt which is received back does not show a date of delivery. [d] The return
receipt which is received back shows an incorrect date of delivery. [e] The return
receipt which is received back does not show a new address where delivered when
there is one. [f] The return receipt which is received back does not have the box
checked to show that there was no change of delivery address. [g] The return receipt
which is received back was mailed by the delivery office later than the next business
day following delivery. [h] The return receipt which was received back utilizes a rubber
stamp or other automated signature which does not meet the requirements of POM
Section 822.2. [i] There is evidence that the accountable mail was delivered to the
addressee to complete the return receipt at a later, more convenient time and therefore
the return receipt was not obtained by the Postal Service at the time of delivery. jj] The
return receipt is not received. [k] A duplicate return receipt indicates that the article
was not delivered. [I] The article is returned by the Postal Service without delivery. [m]
Confirm, and explain if you are unable to do so, that the referenced DMM section also
implies that the return receipt which is furnished meets the requirements of the Postal
Service. [n] Explain any of the items for which a refund of the return receipt fee would
not be authorized. [o] Confirm, or explain if you are unable to do so, that the necessity
of a sender to request a duplicate return receipt just to fix a problem caused by the
improper completion of the original return receipt will reduce the vallue of the service to
the mailer.
a. Customer would not be entitled to a refund in this case; however, the mailer may
request a duplicate return receipt under DMM 5 S915.4.2.
b. Customer would not be entitled to a refund in this case; however, the mailer may
request a duplicate return receipt under DMM 5 S915.4.2
c. Customer would not be entitled to a refund in this case: however, i:he mailer may
request a duplicate return receipt under DMM 5 S915.4.2
d. Customer would not be entitled to a refund in this case; however, the mailer may
request a duplicate return receipt under DMM 5 5915.4.2
e. Customer would not be entitled to a refund in this case; however, the mailer may
request a duplicate return receipt under DMM § S915.4.2.
19
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
f.
Customer would not be entitled to a refund in this case; however, the mailer may
request a duplicate return receipt under DMM 9 S915.4.2.
g. Customer would not be entitled to a refund in this case.
h. Customer would not be entitled to a refund in this case; however, the mailer may
request a duplicate return receipt under DMM 5 S915.4.2.
i.
It is unclear how this would be known by the sender; however the customer would
not be entitled to a refund in this case.
j.
The customer would be entitled to a refund
k. The customer would be entitled to a refund.
I.
The customer would be entitled to a refund.
m. The DMM speaks for itself. The inference you draw does not appear to be
consistent with the wording of DMM S915.1.6.
n. See responses to subparts a-i, and DMM 5915.1.6.
o. Such a necessity certainly may reduce the value of service if the customer had
expectation of a refund.
20
RESPONSE OF POSTAL SERVICE WITNESS PLUNKE-l-T TO
INTERROGATORIES
OF DAVID 8. POPKIN
DBPAJSPS-36
[a] Confirm, or explain if you are unable to do so, that when
accountable mail is delivered, the addressee will be required to sign for the receipt
of the mail utilizing either a single receipt form, manifest delivery form, or other
computerized listing of the type and number of each accountable mail article. [b]
Confirm, or explain if you are unable to do so, that this signature will always be a
hand signature. [c] If not, provide the authority [and furnish a copy] which
authorizes the delivery without a hand signature. [d] Confirm, or explain if you are
unable to do so, that this record of delivery will be maintained in the post office of
delivery. [e] Confirm, or explain if you are unable to do so, that these records will
be discarded after a period of time. [fj What is the authorized time after which
these records may be discarded? [g] Confirm, or explain if you are unable to do so,
that a mailer who has a return receipt may receive confirmation of its validity by
having the delivery office utilize the delivery record and provide this confirmation. [h]
How would such confirmation be accomplished? [i] Confirm, or explain if you are
unable to do so, that once the delivery records have been discarded, there will be no
record of delivery maintained in the Postal Service. [j] Confirm, or explain if you are
unable to do so, that once the delivery record retention period has passed and the
records discarded, the mailer may no longer obtain confirmation of the validity of the
return receipt. [k] Confirm. or explain if you are unable to do so, that the inability of
a mailer to obtain confirmation of the validity of the return receipt could potentially
reduce the value of the service to the mailer. [I] Confirm, or explain if you are
unable to do so, that the use of the red validating stamp on the return receipt could
mitigate or eliminate this potential loss of the value of the service.
DBPIUSPS-36
Response:
a. Not confirmed.
See DMM 5 D042.2.0
b. Not confirmed. See DMM 5 D042.1.7.g.
c. See response to subpart (b).
d. Confirmed.
A record of delivery will be maintained in the post office of delivery
e. Delivery records are retained for two years
f.
See response to subpart (e)
g, Confirmed.
A duplicate return receipt is not available more than one year after
the date of mailing.
DMM 5 S915.4.1.
h. See DMM § S915.4.0.
i.
Confirmed
Y
RESPONSE OF POSTAL SERVICE WITNESS PLUNKE-lT
INTERROGATORIES
OF DAVID B. POPKIN
j.
Confirmed.
available.
TO
However, a duplicate return receipt would already not have been
See DMM 5 S915.4.1.
k. Though there has been no study to quantify the value customers would place on
confirming the validity of return receipts that are more than two years old, it is
reasonable to assume that such value is negligible.
I.
See response to subpart (k).
22
RESPONSE OF POSTAL SERVICE WITNESS PLUNKEllINTERROGATORIES
OF DAVID B. POPKIN
TO
DBP/USPS-38
[c] Confirm, or explain if your are unable to do so, that a mailer
who is utilizing Insured Mail is not required to declare the full value and may purchase
whatever value insurance is desired [although a claim may not be filed for more than
the value of the article]. [d] Confirm, or explain if you are unable to do so, that the
purchase of insurance is not required by a mailer of any class of mail, regardless of the
value of the article.
DBP/USPS-38
Response:
c. Confirmed
d. Confirmed, though Express Mail rates include limited insurance coverage.
23
RESPONSE OF POSTAL SERVICE WITNESS PLUNKEl-T
INTERROGATORIES
OF DAVID 8. POPKIN
TO
DBP/USPS-50
[a] Confirm, or explain if you are unable to do so, that the proposed
fee for Delivery Confirmation on a manual basis will be 35 or 60 cents and that the fee
for Certificate of Mailing is proposed to be 60 cents. [b] Confirm, or explain if you are
unable to do so, that the proposed fee for Delivery Confirmation on an electronic basis
will be 0 or 25 cents. [c] Confirm, or explain if you are unable to do so, that a customer
will be given a receipt for the parcel. [d] What added information or proof, if any, will
the Certificate of Mailing provide to the mailer of a parcel for the added fee of up to 60
cents over the cost of using the Delivery Confirmation Service? [e] If there is none,
what is the justification of the higher rate for the Certificate of Mailing?
a. Objection filed September 25, 1997.
b. Objection filed September 25, 1997.
c. Not confirmed.
See my response to DFC/USPS-T40-21
b.
d. The only instance where a 60 cent difference occurs is if one compares the fee for
an individual certificate of mailing with the fee for electronic delivery confirmation
used in conjunction with Priority Mail. I believe there are few, if any, customers
interested in both services.
Indeed individual certificates of mailing are most likely to
be used by the customers that would use non-electronic
delivery confirmation
at
fees of 25 cents and 60 cents for Priority and Standard (B) mail respectively
Furthermore,
confirmation
the two services are entirely different.
of mailing, while delivery confirmation
Certificates provide
provides proof of delivery.
see my response to part c. To suggest that fees ought to be comparable
misunderstands
the purposes served by these two products,
e. Individual certificates of mailing have a unit cost of 49 cents. See my testimony
(USPS-T-40,
p. 3), and LR-H-107, p. 18.
24
Also
RESPONSE OF POSTAL SERVICE WITNESS PLUNKCX
INTERROGATORIES
OF DAVID B. POPKii\!
TO
DBP/USPS-51
[a] Confirm, or explain if yoil are unable to do so, that bulk
insurance will only p ai for the lesser of the actual value or the wholesale cost of the
contents, [b] Will this provision also apply to individual insurance? ic] If so, explain
why?
DBPIUSPS-5i
Response:
a. Confirmed, assuming you referto the Postal Service proposal
b. No, individual insurance allows customers to claim the actua;‘.;alue of the contents
up to the amount covered by the fee paid.
c. Not applicable
25
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT
INTERROGATORIES
OF DAVID B. POPKIN
TO
DBPIUSPS-53
[a] Confirm, or explain if you are not able to do so, that under the
proposed regulations if I have merchandise weighing under eleven ounces that l may
either utilize First-Class Mail or Priority Mail. [b] Confirm, or explain if you are not able
t0 do SO, that under the proposed regulations if I have merchandise weighing between
eleven and sixteen ounces that I must utilize Priority Mail. [c] Confirm, or explain if you
are not able to do SO, that under the proposed regulations if I have merchandise
weighing over sixteen ounces that I may either utilize Standard Mail [B] or Priority Mail.
[d] Confirm, or explain if you are not able to do so, that a comparison of all of the
characteristics of Standard Mail [B] vs. Priority Mail, will show that, neglecting the price,
Priority Mail will always be equal to or better than Standard Mail [B], i.e., the delivery
standard for Priority Mail is faster, any parcel between 1 and 70 pounds may be sent by
either service with the same level of preparation, the place of mailing is either the same
or better for Priority Mail, Priority Mail will have free forwarding and return, etc. [e]
Confirm, or explain if you are unable to do so, that a parcel containing merchandise
may be insured regardless of whether the postage is paid at the First-Class Mail,
Priority Mail, or Standard Mail [B] rate. [f] Confirm, or explain if you are unable to do
so, that a parcel containing merchandise may be registered regardless of whether the
postage is paid at the First-Class Mail, or Priority Mail rate. [g] Confirm, or explain if
you are unable to do so, that when Registered Mail is utilized, there is an accounting for
each individual mailpiece between the accountable mail section of the delivering post
office and the delivering employee. [h] Confirm, or explain if you are unable to do so,
that when Insured Mail is utilized, there is no accounting for each individual mailpiece
nor even for the total number of insured parcels between the accouintable mail section
of the delivering post office and the delivering employee. [i] Confirm, or explain if you
are unable to do so, that when Registered Mail is utilized there is an accounting for the
mail as it progresses though the mail system form the acceptance ‘to the delivery. b]
Confirm, or explain if you are unable to do so, that when Insured Mail is utilized, there is
no accounting for the parcel at any time other than when the acceptance employee
provides the mailer with a receipt and when the delivering employee obtains a receipt
from the addressee.
[k] Confirm, or explain if you are unable to do so, that for the
acceptance of the article and the delivery of the article, the security and accountability
between Registered Mail and Insured Mail is either identical or better for Registered
Mail. [I] Confirm, or explain if you are unable to do so, that for the time between the
acceptance of the article and its ultimate delivery, the accountability and security
provided to Registered Mail will be greater than that provided to Insured Mail. [m]
Confirm, or explain if you are unable to do so, that, ignoring any price differential, a
knowledgeable mailer with a merchandise parcel weighing over one pound will always
choose Priority Mail - Registered Mail over Standard Mail [B] - Insured Mail. [n] If you
provide any examples where the knowledgeable mailer referred to in subpart m would
choose Standard Mail [B] - Insured Mail over Priority Mail - Registered Mail, provide an
estimation of the percentage of parcels out of the total number of parcels handled
would fall into that category. Remember, that any price differential mulst be ignored. [o]
Confirm, or explain if you are unable to do so, that the fee for Registered Mail for an
article with a value of $5,000 insurance would be $11.65. [p] Confirm, or explain if you
are unable to do so, that the fee for Insured Mail for an article with a value of $5,000
insurance would be $50.90. [q] Confirm, or explain if you are unable to do so, that a
26
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
mailer having a parcel for which $5,000 insurance is desired would pay $39.25 more for
Insured Mail compared to Registered Mail. [r] Based on the above, confirm, or explain
if you are unable to do so, that a knowledgeable
mailer with a parcel containing
merchandise and weighing under one pound and for which $5,000 insurance coverage
is desired will always choose Registered Mail over Insured Mail. [s] Based on the
above, confirm, or explain if you are unable to do so, that a knowledgeable mailer with a
parcel containing merchandise and weighing over one pound and for which $5,000
insurance coverage is desired will always choose Registered Mail over Insured Mail in
those rate cells where the Priority Mail rate is $39.25 or less compa,red to the Standard
Mail rate for the same zone and weight. [t] Provide a listing of all Standard Mail rate
cells where the Priority Mail rate for the same zone and weight is $39.26 or more
greater than the Standard Mail rate for the same zone and weight.
[u] What
percentage of all parcels sent by Standard Mail or Priority Mail fall into those rate cells
provided in response to subpart t? [v] What would United Parcel Service charge an
individual shipper for $5,000 insurance?
[w] Based on the above, how could a
knowledgeable mailer perceive the rates for insurance as being fair and equitable? [x]
Confirm, or explain if you are unable to do so, that the rate for Express Mail insurance
is $45.00 for $5,000 coverage. [y] Confirm, or explain if you are unable to do so, that a
mailer having a parcel for which $5,000 insurance is desired would pay $33.35 more for
Express Mail Insured Mail compared to Registered Mail. [z] Confirm, or explain if you
are unable to do so, that Express Mail may not be registered. [aa] If so, provide a
rationale for such a regulation, [bb] Confirm, or explain if you are unable to do so, that
the rate for Express Mail will always be greater than that for Priority Mail. [cc] Confirm,
or explain if you are unable to do so, that the level of service for Express Mail will
always be greater than or equal to that for Priority Mail. [dd] What do United Parcel
Service, Federal Express, and other major carriers charge their individual overnight
shippers for $5,000 insurance? [eel Based on the above, how could a knowledgeable
mailer perceive the rates for Express Mail insurance as being fair and equitable. [ff]
Confirm, or explain if you are unable to do so, that a mailer with a parcel for which
$5,000 coverage may decide to accept the slower Priority Mail compared to the faster
Express Mail because of the added $33.35 difference in insurance rates between
Registered Mail and Express Mail insurance rates.
DBPAJSPS-53
Response:
a. Confirmed.
Though you would not be limited to those two choices.,
b. Not confirmed.
c. Confirmed.
For example, you may use Express Mail.
Though you would not be limited to those two choices.
d. Confirmed.
e. Confirmed.
f.
Answered by witness Needham.
g. Answered by witness Needham.
27
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
h. Confirmed.
i.
Answered by witness Needham.
j.
Confirmed.
k. Confirmed.
I.
Confirmed.
m. Not confirmed.
I can not assert that all mailers value the same service attributes
equally.
n. I am unaware of any available volume data that would provide the requested
information.
o. Answered by witness Needham.
p. That would be the fee under the proposed schedule.
q. Confirmed.
r. Not confirmed.
See response to subpart (m).
s. Not confirmed.
See response to subpart (m).
t.
Objection filed September 25, 1997.
u. Volume data are contained in USPS-LR-H-145.
v. The UPS published rate for insurance is $0.35 for each $100 in value greater than
$100.
w. Please refer to my testimony USPS-T40, pp. 3-9.
x. Objection filed September 251997.
y. Objection filed September 251997.
z. Answered by witness Needham.
aa. Answered by witness Needham.
bb. Not confirmed.
I can not predict what may happen to rates in the future.
cc. Not confirmed.
I can not predict what may happen to rates in the future.
dd. Published price schedules for these carriers can be obtained through their web
sites.
ee. Please refer to my testimony USPS-T-40,
ff. Confirmed.
pp. 3-9.
RESPONSE OF POSTAL SERVICE WITNESS PLUNKET-T TO
INTERROGATORIES
OF DAVID B. POPKIN
DBPIUSPS-62
Provide a listing for each of the following services indicate, 1. the
rate being proposed; 2. the cost for providing the service for the proposed rate, 3. the
cost coverage percentage for the proposed rate, 4. the present rate, 5. the cost of
provided the service for the present rate, and 6. the cost coverage percentage related
to the existing rate: [a] Fee Group C - PO Box size 1, [b] size 2. [c] size 3, [d] size
4, [e] size 5, [f] Fee Group C - Caller Service, [g] Certified Mail [also provide data
for pre-MC96-3 rate], [h] Return Receipt, [i] Return Receipt for Merchandise,
[j]
Return Receipt issued after mailing, [k] individual Certificate of Mailing, [I] Special
Handling, [m] Single Stamped Envelope, [n] Single Hologram Stamped Envelope, [o]
Plain box of 500 stamped 6-3/4 size envelopes, [p] size 10 envelope, [q] processing
and handling a stamped card, [r] processing and handling a post ca.rd, and [s] fee for
the stamped card itself.
DBP/USPS-62
h.1. $1.45
h.2. $0.97 excluding contingency
h.3. Cost coverage is normally calculated on a subclass or special s,etvice basis. The
implied cost coverage is (1.45/0.97 = 149%).
h.4. $1.10
h.5. $0.97 excluding contingency
h.6. Cost coverage is normally calculated on a subclass or special service basis. The
implied cost coverage is (1.10/0.97 = 113%).
i.1. $1.70
i.2. $1.16 excluding contingency
i.3. Cost coverage is normally calculated on a subclass or special service basis.
implied cost coverage is (1.70/l. 16= 147%).
The
i.4. $1.20
i.5. $1 .16 excluding contingency
i.6. Cost coverage is normally calculated on a subclass or special service basis.
implied cost coverage is (1.20/l. 16 = 103%).
j.l. $7.00
j.2. $6.61 excluding contingency
29
The
RESPONSE OF POSTAL SERVICE WITNESS PLUNKETT TO
INTERROGATORIES
OF DAVID B. POPKIN
j.3. Cost coverage is normally calculated on a subclass or special service basis.
implied cost coverage is (7.00/6.61= 106%).
The
j.4. $6.60
j.5. $6.61 excluding contingency
j.6. .Cost coverage is normally calculated on a subclass or special service basis. The
implied cost coverage is (6.60/6.61 = 99.8%).
k.1. $0.60
k.2. $0.49 excluding contingency
k.3. Cost coverage is no,rmally calculated on a subclass or special rsetvice basis. The
implied cost coverage is (0.60/0.49= 122%).
k.4. $0.55
k.5. $0.49 excluding contingency
k.6. Cost coverage is normally calculated on a subclass or special service basis. The
implied cost coverage is (0.55/0.49 = 112%).
30
_-
RESPONSE OF P0STg.L SE: n/ICE WIT’YESS PLUNKETT TO
INTERROGATQ=?!ES CF @AVID B. POPKIN
Refer to interrogatory DBP/USkS-27.
[a] With respect to the new
DBPIUSPS-64
Return Receipt service showing the new address of deiivery, has Headquarters or any
Area prepared a training course or other training material to explain the new service?
[b] If so, provide copies of the training material. [c] If not,. add that reason into your
response to subpart f of DBP/USPS-27.
DBP/USPS-64
Response:
a. Yes
b. Materials will be filed as LR-H-266.
c. Not applicable.
31
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
with section ‘12 of the Rules of
Practice.
~4?i/r3nm
David H. Rubin
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 137
September 29, 1997
upon all
DECLARATION
I, Michael
answers
are true
K. Plunkett,
and correct,
declare
to the
under
best
penalty
of perjury
of my knowledge,
MICHAEL
that
the foregoing
information,
K. PLUNKETT
and belief.